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In an amazing flash of Acme Legal expertise, the Dreadful Pro-Se Schmalfeldt is threatening to amend his complaint in Schmalfeldt v. Grady. However, under Fed. R. Civ. P. 15, his last day to amend his complaint as a matter of course was 29 June, i.e., 21 days after Patrick Grady filed his motion to dismiss under Rule 12(b)(2).

It’s still possible for him to amend his complaint, but that now requires either Grady’s concurrence (fat chance) or the court’s permission.